Here is the situation... we have a loan that just prior to maturity the borrower was encouraged to go elsewhere for financing. In the meantime however we have offered to work with them.. we did a change in terms to extend the maturity date for two months while they waited for approval from another lender... they did not get it in time so we extended another 2 months. So, based on information from our last CRA exam... the CRA Offcier feels she can count this loan twice ...

This just seems incorrect to me... one time I get because technically no one else would make this loan... but it seems like (2 or more perhaps is overkill). Can anyone help with this and is there guidance? Thank you

If there was new money on a renewal/refi/mod, you get a second trip to the well for the new money only. Otherwise, you report once per calendar year.

From the Q and A:

§ll.42(a)—5: Should institutions
collect and report data about small
business and small farm loans that are
refinanced or renewed?
A5. An institution should collect
information about small business and
small farm loans that it refinances or
renews as loan originations. (A
refinancing generally occurs when the
existing loan obligation or note is
satisfied and a new note is written,
while a renewal refers to an extension
of the term of a loan. However, for
purposes of small business and small
farm CRA data collection and reporting,
it is not necessary to distinguish
between the two.) When reporting small
business and small farm data, however,
an institution may only report one
origination (including a renewal or
refinancing treated as an origination)
per loan per year, unless an increase in
the loan amount is granted. However, a
demand loan that is merely reviewed
annually is not reported as a renewal
because the term of the loan has not
been extended.
If an institution increases the amount
of a small business or small farm loan
when it extends the term of the loan, it
should always report the amount of the
increase as a small business or small
farm loan origination. The institution
should report only the amount of the
increase if the original or remaining
amount of the loan has already been
reported one time that year. For
example, a financial institution makes a
term loan for $25,000; principal
payments have resulted in a present
outstanding balance of $15,000. In the
next year, the customer requests an
additional $5,000, which is approved,
and a new note is written for $20,000.
In this example, the institution should
report both the $5,000 increase and the
renewal or refinancing of the $15,000 as
originations for that year. These two
originations may be reported together as
a single origination of $20,000.

Thank you, it makes so much more sense...the only time you get to count it again is if there is new money.

In the case of a modification on a demand note - would the originated amount and the increased amount be reported separately if the note was originated for $500K and increased to $600K in the same year (2015) or would only the $600K be reported?
Thanks!

You could report either way. You could have two separate LR entries with a unique identifier.

I took the easier (Ahem... lazier) way and reported the latter action for the whole amount. Just make sure you are consistent about how you report multiple actions and make sure you have this documented in procedures.

best of luck!

Thank you!!